CIRCUIT COURT, EIGHTEENTH JUDICIAL CIRCUIT,
IN AND FOR SEMINOLE COUNTY, FLORIDA

Michael Thomas Harbuck
P.O. Box 1341 
Sanford, FL   32772

VS.

Cambata Aviation Int'l LLC , Nelson Cambata registered agent
Orlando Sanford International Airport
100 StarPort Way, Sanford, FL 32773

COMPLAINT
	Having occurred, and containing a seat of the defendant who is a registered Florida company ,  within the jurisdiction of the court,
	The PLAINTIFF,  Michael Thomas Harbuck,  contends  herewith, and files with the court,  that he has suffered damages from the defendant according to Title VII of the Federal Law, regarding a sexually harassing workplace,  which did cause suffering and emotional pain, and inconvenience.
The plaintiff contends that there was a malicious slander by two employees, whose names are unknown to the plaintiff, whereby  his reputation and character was defamed, causing either directly or indirectly the loss of wages, and career defamation, and emotional pain and suffering.
Lastly, the plaintiff contends, that because of his bringing forth the points of sexual harassment to superiors, that he was wrongfully deprived of income, in that he was laid off, and thus discriminated against because of voicing concern for, and dislike of the hostile work environment.
I
Sexual Harassment 
A.
1.  A supervisor was notified by the plaintiff of a particularly offensive conversation of boisterous depictions of an extremely vulgar sexual  nature which occurred in the common area of the place of employment,  which did blatantly exceed ordinary socializing.
2.  One particular instance of inappropriate sexual conversation,  being malicious and purposeful in intent by two certain employees, whose names are unknown to the plaintiff,   did so offend the plaintiff, that he immediately voiced his concern, which was met with a barrage of explicative and accusations, belittling the plaintiff, by the same two offending employees.  It is generally known to a majority at Starport that sexual, and offending remarks by the two certain employees occurred in a continuous and unfortunately acceptable manner.  This behavior did exceed ordinary social behavior, and was offensive to the plaintiff, and did cause suffering and emotional pain.  
B.
After being reprimanded under a  false accusation, a supervising employee,  in two separate instances made vivid remarks regarding his intensions, and want of receiving oral sex from the plaintiff.  These actions did cause suffering and mental anguish, and added to the already hostile and sexually harassing workplace.  The fear of retribution and further slander did worsen the anguish received from the malicious slander.
“In Bundy v. Jackson, the District of Columbia Circuit Court of Appeals characterized hostile environment cases as presenting a "cruel trilemma."   In Bundy the victim had three options: (1) to endure the harassment, (2) to attempt to oppose it and likely make the situation worse, or (3) to leave the place of employment.   A hostile work environment, the court held, represented discrimination under Title VII and constituted grounds for legal action.”
II
Defamation
The offending employees did maliciously slander the plaintiff by concocting false accusations to cover the intentional sexually harassing and offensive environment, and in particular the afore mentioned (I,A,2) single conversation arising from the confrontation between the plaintiff and the two offending employees.    The plaintiff was falsely accused before the management,  and was reprimanded for an act which he did not commit.  The accusation was of such a severe nature, that the plaintiff did suffer an extreme feeling of betrayal, and disbelief, which soon became a fear of the company, and of being reprimanded further for something else which he did not do.  
III
Employment discrimination
The plaintiff was laid off during a business lull not long after having refused to sign a formal reprimand for the false accusation which was to be placed in his employee file, being told that is was a temporary  layoff,  and that he would be rehired within a four to six week period.  Having immatriculated himself shortly before, as well as having received a positive six month evaluation, in addition to a significant 30 percent raise, the plaintiff was at a loss, which hindered his intended career and school plans significantly.  the plaintiff, now unemployed at the holidays, was damaged by the lost wages .
Demand for Damages	
WHEREFORE is it demanded that damages be paid by the DEFENDANT to the PLAINTIFF, and that the  following be satisfied before the court :
1.  the sum of one hundred thousand U.S. Dollars (100,000.00) regarding the sexual harassment.  
2.  that punitive damages of a sum deemed reasonable by the court to be paid to any Florida     Organization which helps battered women, and or rape victims.  
3.   that the two employees who slandered and belittled the plaintiff make a formal apology in front of the court to the plaintiff.
4.   that the supervisor who harassed the plaintiff make a formal apology in front of the court to the plaintiff.
5.  that the lost wages with interest be paid in full from the date of the layoff up  to the last day of civil litigation regarding this matter, including any and all legal fees involved.  
6.  that Cambata Aviation Int'l LLC implement a sexual harassment plan written and signed by the management, and shown to the court.  
7.  any compensation the court deems acceptable using current laws and cases.  

STATE OF FLORIDA
COUNTY  OF SEMINOLE

	I,  Michael Thomas Harbuck, the PLAINTIFF, state that the foregoing is a just and true statement, and or complaint, and an accurate account of the occurrences described herein.  

______________________________ 			Sworn to and subscribed before me by
Plaintiff							______________________________
							
Michael Thomas Harbuck				who is personally know to me or produced
130 Anderson Road 						______________________________
Roxboro, NC 						as identification this _____ day of__________,
Tel. (407) 454- 4246					in the year______.
(336) 599#-1579					Deputy Clerk or Notary Public
							State of ___________________
							My commission expires: